Privacy Policy

Last modified: August 01, 2020

Thanks for using our products and services ("Services"). The Services are provided by nobrodev ("nobrodev.com"), located at 13485 Bryant St, Suite 200, San Francisco, CA, USA, 94107 .

By using our Services, you are agreeing to these terms. Please read them carefully.

Our Services are very diverse, so sometimes additional terms or product requirements (including age requirements) may apply. Additional terms will be available with the relevant Services, and those additional terms become part of your agreement with us if you use those Services.

We, at nobrodev, LLC. (“we” or the “Company”), are committed to protect the privacy of:

1. individuals who visit or access our website at nobrodev.com (the “Website”);
2. our customers and business partners (“Customer(s)”), who are licensed to access or use the platform (the “nobrodev.com Platform”) and any other services offered by the Company (collectively with the nobrodev.com Platform and Website: the “Services”). Please note that although we do not intend that our Customers will share Personal Information with us, if we do process Personal Information on behalf of our Customers, we will process it in accordance with the provisions of this policy, as applicable;
3. any individual who is authorized by our Customers to use our Services or has access to any of the data managed and analyzed by the Company (“User(s)”).

Please note that the term “you” shall refer to Website’s visitors, Customers and Users, as applicable.

The term “GDPR” shall mean the General Data Protection Regulation (Regulation (EU) 2016/679).

The term “CCPA” shall mean the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1789.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General.

Our privacy policy (“Privacy Policy”) will help you understand what information we collect through the Services, how the Company uses it, and what choices you have. We transmit, process, or store as little data as possible. However, we are an online website and as such, some information is required for a client and server to communicate. We encourage you to read and understand this Privacy Policy. By using our Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to it.

Our mission to build a safer, more secure Internet.  Our commitment is rooted in high integrity to earn and maintain the trust of our Customers, users, and the global community. To earn and maintain that trust, we commit to transparently, providing security, and protecting the privacy of data of our customers.

We keep your personal information personal and private. We will not sell or rent your personal information to anyone. We will not share or otherwise disclose your personal information except as necessary to provide our Services or as otherwise described in this Policy without first providing you with notice and the opportunity to consent.

When connected to nobrodev’s Private Portal, you may access websites or surf the web at your discretion. As you surf the web, we do not log or have access to the following data:
-Any DNS queries while connected. We rely on our own secure DNS servers, so your queries are also protected from exposure to 3rd parties.
• Browsing history.
• Transferred data.
• Files (Home Directory contents).
• Copy/Paste history, clipboard, or otherwise.
• Personal settings, configurations, or related.

 

If you have a visual disability, you may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Privacy Policy.

In this Privacy Policy we will cover:
• What information we collect?
• Cookies
• How we use the information that we collect?
• Who or how is this information shared (if at all)?
• EU residents
• California residents
• General Provisions
      o For how long do we retain the information that we collect?
      o How do we safeguard your information?
      o Advertisements
      o Marketing
      o Corporate transaction
      o Minors
      o Updates or amendments to the Privacy Policy
      o Contact us

We may collect the following types of information from or about you:

Personal Data Use

Personal Information is individually identifiable information, namely information that identifies an individual or may with reasonable effort to identify an individual. Although we capture as little data as possible, we operate on the internet, and as such there is some information required to function online.

Personal data is understood as any information that relates to an identified or identifiable natural person and includes the information you provide to us while using our Services. More specifically, we may collect and process personal data about you in the following situations in order to better protect you and improve our services to bring you a better service offering.

We may gather the following types of Personal Information:

• Account details: When you Signup for our Services, you provide certain information, including but not limited to your email address, to authenticate and log into our website and Private Portal.
• Email address: We use your email address as you username, to authenticate and log into our website. Upon signup, you provide us with your email address, so that we can send you a verification code to verify your email. Once registered and verified, you will use this information as your login details to access our site and services.
• Billing & Payment: We rely on third-party payment processors to handle your product purchases. You can find out which provider we are working with for the point of purchase you chose, by looking at your transactional email or receipt.
• Registration details: When ordering or registering to our Services, we may collect certain information that can be used to identify you (as the Customer’s point of contact or as a User) such as: name, email address, postal address, phone number, user ID, and other relevant details which are relevant to the Customer.
• Customer’s payment information: In order for you to enjoy all of the functions which we offer, we collect payment information from you, including your credit card number and bank account details. Please note that your billing information, to the extent provided by you, is forwarded directly to a third party billing or clearing company engaged by us and is not kept by us.
• Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, ask our support, and communicate with us in any means, including, without limitation, via email, phone, Website, nobrodev.com Platform or otherwise, or when you share additional information about yourself through your use of the Services, then all such communications may be recorded.
• Device information: We also collect specific types of connection details and information regarding your device, software or hardware that may identify you, such as: online identifiers, device’s unique identifiers (e.g. UDID), IP address and geolocation.

Non-Personal Data Use

Personal Information is individually identifiable information, namely information that identifies an individual or may with reasonable effort to identify an individual. Although we capture as little data as possible, we operate on the internet, and as such there is some information required to function online.

• Analytics Data & Product functionality: connection time, duration, etc. This information can be used for technical or connectivity troubleshooting. Analysis of this data can be used to improve our platform’s security and to improve performance, availability, etc. Our servers automatically record certain information regarding the use of our Services. Such data is also used for troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services. For the avoidance of doubt, if we combine Personal Information with Non-Personal Information (e.g. analytics data), the combined information will be treated as Personal Information as long as it remains combined.

• Anonymous information: We may anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. Our use and disclosure of such aggregated or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation and for any purpose.

If you have any reason to believe that our Services are misused, in any way, please do not hesitate to contact us.

When you visit or access our Websites, or when you interact or engage with our Services, we use (and authorize third parties to use) web beacons, cookies, pixel tags, scripts, tags, API and other technologies (“Tracking Technologies”).

The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, Customers and partners.

We also allow third parties to collect information about you through Tracking Technologies for the same purposes mentioned above.

Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at https://www.allaboutcookies.org/.

Cookies are widely used in order to make websites work in an efficient way. The use of cookies allows you to navigate between pages efficiently. Cookies remember your preferences and make the interaction between you and the Services smoother and more efficient. Cookies are also used to help ensure that the advertisements you see online are relevant to you and your interests.

There are four main types of Tracking Technologies:

• Strictly necessary Tracking Technologies – These Tracking Technologies are essential to enable you to login, navigate around and use the features of our Services, or to provide a service requested by you (such as your username). We do not need to obtain your consent in order to use these Tracking Technologies. These Tracking Technologies can be used for security and integrity reasons – for example, to detect violation of our policies and for support or security features.

• Functionality Tracking Technologies – These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged in) and support other features of our Services.

• Performance Tracking Technologies – These Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).

• Social media Tracking Technologies – Our website includes social media features, such as the Facebook “Like” or “Share” buttons. These features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy statement of the company providing these features.

In addition to the purposes listed herein, the information we collect, which may include your Personal Information, is used for the following purposes:
• To set up Customers’ accounts and process billing information;
• To identify and authenticate Users’ access to our Services;
• To provide Services to our Customers (or Users).
• To support and troubleshoot our Services and to respond to queries.
• To obtain Users’ feedback with regards to our Services.
• To improve and customize our Services to Customer’s needs and interests;
• To communicate with you and to keep you informed of our latest updates and newsletters;
• To investigate violations, fraud, and abuse of our services and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

We do not rent or sell any Personal Information.

This part of the Privacy Policy addresses the specific requirements and rights under the GDPR.

Legal basis for processing

Processing of Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and to comply with our legal obligations.

Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object.

If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.

Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the European Union. In these instances, we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.

Rights under the GDPR

You may contact us at any time and request:
• To access, delete, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
• That we will cease or limit any further use of your Personal Information (for example, you may ask that we will stop using or sharing your Personal Information with third parties);

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

If you wish to raise a complaint on how we have handled your Personal Information, you can contact our Data Protection Officer who will investigate the matter. Our Data Protection Officer can be contacted here.

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws and regulations, you can file a complaint to the applicable supervisory authority.

This part of the Privacy Policy addresses the specific requirements under the CCPA.

Collecting Personal Information

In the preceding twelve (12) months, we have collected the following categories of Personal Information:
• Identifiers
• Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
• Internet or Other Electronic Network Activity Information

Sharing Personal Information

We do not sell or disclose your Personal Information to third parties. We use third parties on our website, such as Shopify or other payment processing companies. In this case, you are sharing your information directly with them and not us.

Selling Personal Information

We do not and will not sell your Personal Information to third parties (according to the CCPA definition of a “sale”) and businesses for commercial purposes.

In the preceding twelve (12) months, we did not sell any Personal Information third parties or businesses for commercial purposes.

Rights under the CCPA

Access to Personal Information:
You may request that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable.

Deletion requests:
You have the right to request that we delete any Personal Information collected from you and retained, unless retaining the information is necessary for us or for our service providers to:
• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing or intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors and consultants to delete) your Personal Information, unless an exception applies.

Exercising your rights

You can exercise your rights (such as access and deletion) by submitting a verifiable consumer request to us at our contact form.

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:
• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may only request a copy of your data twice within a 12-month period.

If you have any general questions about the Personal Information that we collect about you and how we use it, please contact us here. 

Response timing and format

Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the 45 days period. If you are a User or Customer, we will deliver our written response to your through your Customer account. If you are a Website visitor, we will deliver our response by mail or electronically, at your option. Any disclosures we provide will cover only the 12-month period preceding the request. If reasonably possible, we will provide your Personal Information in a format that is readily useable and should allow you to transmit the information without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.

Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.

Designating agents

You can designate an authorized agent to make a request under the CCPA on your behalf if:
• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and • You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code §§ 4000–4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

General Provisions

The following provisions apply for all Personal Information processed by us.

We retain the information as short as possible, that we collect from Customers and Users for as little as needed to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing Customers’/Users’ Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

We take great care in implementing and maintaining the security of the nobrodev.com Platform, your information and End-User Data. We employ industry standard procedures to ensure the confidentiality, integrity, and availability of our Customers’ systems and End-User Data, the safety of your Personal Information and prevention of unauthorized use of any such information. Our staff have decades of security and privacy experience and we use that knowledge to bring to you a world-class security program and data protection.

However, some hackers are good, really-good; we cannot guarantee that hackers or unauthorized personnel will not gain access to information despite our efforts. You should note that by using our Services, your information will be transferred through third party infrastructures which are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information and End-User Data, we cannot guarantee its absolute security.

If you feel that your privacy was treated not in accordance with this Privacy Policy, please contact us directly.

We use third parties services for email, survey and marketing campaigns. We may use your Personal Information, such as your name, email address, etc. for the purpose of providing you with promotional materials, concerning our Services. This includes the use of MailChimp or Survey Monkey to assist us in email campaigns, surveys, etc. Out of respect to your right to privacy, we provide you within such marketing materials with means to decline receiving further marketing offers from us. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by contact us directly.

We may use your Personal Information, such as your name, email address, etc. ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our Services. This includes the use of MailChimp or Survey Monkey to assist us in email campaigns, surveys, etc. Out of respect to your right to privacy, we provide you within such marketing materials with means to decline receiving further marketing offers from us. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by contacting us here. 

Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.

We may share information, including Personal Information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will respect the rights and obligations as described in this Privacy Policy.

The Services are not designated to individuals under the age of 16. If you are under 16 you should not use the Services nor provide any Personal Information to us.

We reserve the right to access and verify any Personal Information which is collected from you by us. In the event that we become aware that an individual under the age of 16 shared any Personal Information, we will discard such information. If you have further questions, please contact us here.

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our Website (as reflected in the “Last Revised” heading). We encourage you to review this Privacy Policy regularly for any changes.

Your continued use of the Services, following the posting of such amendments on our Website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

If you have any additional questions regarding our Privacy Policies, Services, or the information we collect and how we use it, please contact us through our online contact form.